On 23 October 2017, the Bangalore Income Tax Appellate Tribunal issued its decision on whether distribution fees paid in respect of Adwords in India should be treated as royalties for withholding tax purposes. The case involved Google India Private Ltd (Google India), which under a distribution agreement was granted non-exclusive marketing and distribution rights to essentially resell Google Adwords online advertising space to Indian customers and provide related after sales service to the India advertisers. As part of the agreement, Google India collected and remitted payments of approximately INR 14.57 billion (~USD 224 million) to Google Ireland in the years...